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United States securities and exchange commission logo





                            February 16, 2023

       Tom Brock
       Chief Financial Officer
       Energy Fuels Inc.
       225 Union Blvd. Suite 600
       Lakewood, CO 80228

                                                        Re: Energy Fuels Inc.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2021
                                                            Filed March 15,
2022
                                                            File No. 001-36204

       Dear Tom Brock:

              We have reviewed your January 23, 2023 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       December 21, 2022 letter.

       Form 10-K for the Fiscal Year ended December 31, 2021

       Description of Properties, page 53

   1.                                                   We understand from your
response to prior comment 1 that you will disclose metallurgical
                                                        recoveries for each
material property when filing your next annual report. Please provide
                                                        us with the details of
your intended disclosure for further review.
       Exhibits and Financial Schedules, page 189

   2.                                                   We note your response
to prior comment 3 regarding the assumptions underlying the cut-
                                                        off grades in the
technical report summaries, identifying various locations within the
                                                        exhibits were relevant
details appear, and providing some incremental clarification of
                                                        rationale for the
cut-off grades utilized for certain properties.
 Tom Brock
Energy Fuels Inc.
February 16, 2023
Page 2
       Your explanation of the Nichols Ranch cut-off grade indicates that the
ISR cut-off grade
       calculations are different than a traditional cut-off grade calculation.
However, your
       description of the Alta Mesa ISR cut-off grade calculation appears to
include modifying
       factors that would be used in a more traditional cut-off grade
calculation. Please explain
       to us your reasons for these apparent differences in methodologies.

       With regard to the assertion provided in your response stating "The fact
that the Nichols
       Ranch Project shows positive economics utilizing the 0.2 GT cut-off
should be the primary
       factor in determining the Reasonable Prospect of Economic Extraction and
is therefore a
       valid cut-off," please clarify whether this more definitive view will be
provided by the
       qualified person in Section 14.10.1 of the Nichols Ranch technical
report summary, to
       either accompany or replace the present language referencing some
familiarity with cut-
       off criteria applied in similar operations, and offering concurrence
that a 0.2 GT cut-off
       meets the criteria for reasonable economic extraction via ISR.

       Please reconcile the minimum geologic grade value of 0.02 % U3O8 that is
associated with
       Nichols Ranch in your response and on pages 14-15 of the corresponding
technical report
       summary, with the 0.05% U3O8 value disclosed on page 57 of your annual
report.

      You may contact John Coleman, Mining Engineer, at (202) 551-3610, or Karl
Hiller,
Branch Chief, at 202-551-3686 if you have any questions regarding the comments.



                                                             Sincerely,
FirstName LastNameTom Brock
                                                             Division of
Corporation Finance
Comapany NameEnergy Fuels Inc.
                                                             Office of Energy &
Transportation
February 16, 2023 Page 2
cc:       James Guttman - External Counsel
FirstName LastName
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